Privacy Policy

Privacy Policy

Privacy Policy

Valid from: To be confirmed

General provisions

General provisions

This Privacy Policy (hereinafter – Policy) is intended to inform you about how (LuxTrans S.A.R.L, registration Nr. B 227977, registered address 23 rue Jean Pierre Sauvage, L-2514 Luxembourg (hereinafter – the Company or We), processes your personal data, as well as about your rights regarding the Company‘s processing of personal data.

This Policy has been prepared in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter – GDPR) as well as other legal acts regulating the protection of personal data.

The Company seeks to implement the following essential principles related to personal data processing through this Policy:

Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject (lawfulness, fairness and transparency principle);

Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (purpose limitation principle);

Personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (data minimisation principle);

Personal data shall be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (accuracy principle);

Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (storage limitation principle);

Personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (integrity and confidentiality principle).

Processing of personal data

Processing of personal data

Below we present your personal data collected and processed by the Company, as well as the purposes of personal data processing, the legal basis, and the retention periods:

Purpose

Personal Data

Legal Basis

Retention period

Registration and verification on the platform

Name Surname Email address Phone number Address Workplace and Position Personal data of the ID document or self-employment certificate

Contract (GDPR Art. 6(1)(b))

10 years after the execution of the contract

Using the platform

Name Surname Email address Phone number Address Geolocation data Workplace and Position Signatures of the driver and vehicle receiver on the CMR consignment note. Date, time and content of communication on the platform IP address

Contract (GDPR Art. 6(1)(b))

10 years after the execution of the contract

Direct marketing

Name Surname Email address Phone number

Consent (GDPR Art. 6(1)(a)) or our legitimate interest (GDPR Art. 6(1)(f)), if you are the Company client who has been using our platform services within 7 years

Until you opt-out of receiving direct marketing notifications or if you have not used our platform for more than 7 years

Communication with us

Name Surname Email address Phone number Personal data of the ID document or self-employment certificate Date, time, and content of communication

Legitimate interests (GDPR Art. 6(1)(f))

10 years from the receipt of the relevant communication

Financial accounting

Name Surname Personal data of the ID document or self-employment certificate

Legal obligation (GDPR Art. 6(1)(c))

10 years

Execution of contracts with Company counterparties

Name Surname Email address Phone number Address Workplace and Position

Contract (GDPR Art. 6(1)(b))

10 years after the execution of the contract

Registration and verification on the platform — Personal Data: Name Surname Email address Phone number Address Workplace and Position Personal data of the ID document or self-employment certificate. Legal Basis: Contract (GDPR Art. 6(1)(b)). Retention period: 10 years after the execution of the contract

Using the platform — Personal Data: Name Surname Email address Phone number Address Geolocation data Workplace and Position Signatures of the driver and vehicle receiver on the CMR consignment note. Date, time and content of communication on the platform IP address. Legal Basis: Contract (GDPR Art. 6(1)(b)). Retention period: 10 years after the execution of the contract

Direct marketing — Personal Data: Name Surname Email address Phone number. Legal Basis: Consent (GDPR Art. 6(1)(a)) or our legitimate interest (GDPR Art. 6(1)(f)), if you are the Company client who has been using our platform services within 7 years. Retention period: Until you opt-out of receiving direct marketing notifications or if you have not used our platform for more than 7 years

Communication with us — Personal Data: Name Surname Email address Phone number Personal data of the ID document or self-employment certificate Date, time, and content of communication. Legal Basis: Legitimate interests (GDPR Art. 6(1)(f)). Retention period: 10 years from the receipt of the relevant communication

Financial accounting — Personal Data: Name Surname Personal data of the ID document or self-employment certificate. Legal Basis: Legal obligation (GDPR Art. 6(1)(c)). Retention period: 10 years

Execution of contracts with Company counterparties — Personal Data: Name Surname Email address Phone number Address Workplace and Position. Legal Basis: Contract (GDPR Art. 6(1)(b)). Retention period: 10 years after the execution of the contract

Registration and verification on the platform — Personal Data: Name Surname Email address Phone number Address Workplace and Position Personal data of the ID document or self-employment certificate. Legal Basis: Contract (GDPR Art. 6(1)(b)). Retention period: 10 years after the execution of the contract

Using the platform — Personal Data: Name Surname Email address Phone number Address Geolocation data Workplace and Position Signatures of the driver and vehicle receiver on the CMR consignment note. Date, time and content of communication on the platform IP address. Legal Basis: Contract (GDPR Art. 6(1)(b)). Retention period: 10 years after the execution of the contract

Direct marketing — Personal Data: Name Surname Email address Phone number. Legal Basis: Consent (GDPR Art. 6(1)(a)) or our legitimate interest (GDPR Art. 6(1)(f)), if you are the Company client who has been using our platform services within 7 years. Retention period: Until you opt-out of receiving direct marketing notifications or if you have not used our platform for more than 7 years

Communication with us — Personal Data: Name Surname Email address Phone number Personal data of the ID document or self-employment certificate Date, time, and content of communication. Legal Basis: Legitimate interests (GDPR Art. 6(1)(f)). Retention period: 10 years from the receipt of the relevant communication

Financial accounting — Personal Data: Name Surname Personal data of the ID document or self-employment certificate. Legal Basis: Legal obligation (GDPR Art. 6(1)(c)). Retention period: 10 years

Execution of contracts with Company counterparties — Personal Data: Name Surname Email address Phone number Address Workplace and Position. Legal Basis: Contract (GDPR Art. 6(1)(b)). Retention period: 10 years after the execution of the contract

From where does the Organization receive personal data?

From where does the Organization receive personal data?

We receive your personal data in various ways: When you provide them to us yourself, e.g., by writing, calling, visiting us, submitting documents, registering on the Company‘s platform; From publicly available sources, e.g., public registries, credit assessment companies; Through cookies.

To whom may the Company transfer your personal data?

To whom may the Company transfer your personal data?

The Company ensures the confidentiality of the personal data you provide and does not transfer it to third parties, except for the Organization’s trusted partners (IT service providers, couriers, lawyers, financial accounting service providers, etc.) without whom the Organization could not carry out economic activities and fulfil obligations. These partners may use your personal data only to the extent necessary to perform the specific task, and they are required to comply with strict confidentiality and data protection requirements. In certain cases, the Company may have to disclose your personal data to state institutions, law enforcement agencies, etc. The Company processes your personal data within the EU or EEA, however, in certain cases, we may transfer personal data outside the EU or EEA, in compliance with the requirements set out in Chapter V of the GDPR.

How does the Company protect your personal data?

How does the Company protect your personal data?

The Company applies appropriate technical and organizational measures to ensure the security of the personal data entrusted by you and compliance with the requirements of legal acts regulating data protection.

Your Rights

Your Rights

You have the following data subject rights: The right to receive information about data processing and to access your personal data processed by the Company; The right to object to the processing of personal data; The right to demand the erasure of personal data (the right to be forgotten); The right to receive your personal data in a structured, commonly used, and machine-readable format and the right to transfer those data to another controller without hindrance (the right to data portability); The right to rectify incorrect, incomplete, or inaccurate personal data; The right to demand the restriction of the processing of your personal data; The right to withdraw consent given for the processing of personal data.

You can exercise your rights listed above by contacting us in one of the following ways: By sending a written request via email to: To be confirmed; By sending a written request to or visiting the Company‘s office at: To be confirmed When submitting a request by visiting the Company‘s office, you must provide an identity document to the Company‘s employee for the purpose of identifying you. If the request is submitted via email, it must be signed with a qualified electronic signature. In the event that you send the request to the Company‘s registered office address, a copy of your identity document certified by a notary, or a copy of this document certified in another manner established by legal acts, must be submitted together with the request.

The Company undertakes to respond to your request within 1 month from the day of its receipt. This period may be extended by a further 2 months if necessary, taking into account the complexity and number of requests. The Company has the right not to answer your request if the requirements set out in point 13 of the Policy are not met. When the data subject’s requests are manifestly unfounded or disproportionate, the Organization has the right to charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or to refuse to act on the request. In cases where you believe that your personal data is being processed unlawfully or your rights related to data processing are being violated, you have the right to file a complaint with the local data protection supervisory authority.

Use of Cookies on the Company’s Website

Use of Cookies on the Company’s Website

The Company’s website uses cookies – small text files that your internet browser places on your computer, tablet, or other smart device when you visit our website. Cookies help to recognize you as a previous visitor to the site, save your history of visiting the site, and adapt its content and advertising accordingly. Cookies also help ensure the smooth operation of the website, allow monitoring the duration and frequency of visits to the website, and collect statistical information about the number of site visitors. The following cookies may be used on the Company’s website: Necessary technical cookies – these are cookies that are necessary for the operation of the website. Without them, providing certain website services would become impossible, and the site would not function as smoothly as it should. These cookies do not collect any information for marketing purposes and do not remember what websites you have visited on the internet; Functional cookies – although these cookies are not necessary for the operation of the website, they significantly improve its performance, quality, and user experience. Functional cookies allow the website to remember your choices and provide improved and more personalized features; Analytics (statistics) cookies – these cookies collect information about the use of the website and help improve the website’s performance. Analytics (statistics) cookies do not collect personal user information, and all information collected by these cookies is aggregated and anonymous; Advertising (targeting) cookies – these are cookies used to show offers or other information that might interest you. Below in the table, we provide information about the main cookies used on the Company’s website.

Cookie name

Cookie Type

Cookie Description

Expiry Time

_ga

Statistics cookies

Analytics “Google” cookie designed to distinguish visitors

2 years

_fbp

Advertising cookies

Cookie used by the social network “Facebook”, designed to offer personalized advertising

3 months

You can control the use of cookies by changing your browser settings. You can find more information on how to remove cookies, as well as other useful information related to the use of cookies, on the website http://www.allaboutcookies.org/manage-cookies

_ga — Cookie Type: Statistics cookies. Cookie Description: Analytics “Google” cookie designed to distinguish visitors. Expiry Time: 2 years

_fbp — Cookie Type: Advertising cookies. Cookie Description: Cookie used by the social network “Facebook”, designed to offer personalized advertising. Expiry Time: 3 months

_ga — Cookie Type: Statistics cookies. Cookie Description: Analytics “Google” cookie designed to distinguish visitors. Expiry Time: 2 years

_fbp — Cookie Type: Advertising cookies. Cookie Description: Cookie used by the social network “Facebook”, designed to offer personalized advertising. Expiry Time: 3 months

Other information

Other information

The Company’s website may contain third-party advertising banners and links to their websites and services, which the Organization does not control. We inform you that the Company is not responsible for the safety and privacy of information collected by third parties. Therefore, we recommend that you check the privacy policies published by these third parties in each case before visiting these websites. This Policy may be updated and changed. The Company will inform about updates by publishing the changed text of the Policy on its website. We advise you to periodically visit our website and review the current Policy.